Article 19 Paragraph 9 of the Regulation (EU) 2017/459 (NC CAM) foresees the establishment of virtual interconnection points (VIP). The concerned German Transmission System Operators (TSOs) have informed market participants several times on the intermediate status of implementation as well as on the discussions with the regulatory authorities on European and national level. Today, we would like to inform you about the current status of the implementation of VIPs (4 February 2019).
As the result of the Functionality Process, ACER and ENTSOG have provided jointly developed proposals for amendments of the Network Code CAM to the European Commission (EC) in June 2018 in order to create more legal certainty. During a meeting with representatives of the Member States on 20 June 2018 the EC stated that an amendment to the NC CAM is not feasible before 2020. Furthermore, ACER and ENTSOG have published a letter of the EC dated 6 August 2018. In this letter, the Directorate-General for Energy of the EC communicates its interpretation of the NC CAM requirements. According to the EC, a legal clarification via a prompt NC amendment will not take place. From the EC’s point of view, Art. 19 (9) NC CAM implicitly requires the integration of already contracted capacity in the VIP despite the wording “available capacities”. The Federal Network Agency (Bundesnetzagentur) has already informed the German TSOs that she does not share this interpretation and that in consequence the dual system has to be implemented in Germany. Also the German TSOs thus continue with the implementation of the dual system.
What does the „dual system“ contain in detail?
The main details of the „dual system“- which have been agreed with the Bundesnetzagentur - are listed in the following. The rules apply at the earliest starting on or referring to 01.11.2018. Should the establishment of a VIP be delayed, the rules only apply starting on or referring to the date of the establishment of the respective VIP. It has to be considered that a VIP can only be implemented in case of an agreement on the establishment and the implementation details of the VIP between the partners on both sides of the border. As long as a VIP has not been formed at a border, the current rules for the IPs at that border continue to apply.
The "dual system" in detail
Establishment of a VIP in addition to the existing IP
Contracts that exist on the date of VIP-establishment (existing contracts) remain at the IP. An option to transfer these contracts to the VIPs is not foreseen
The technical capacity at the IP corresponds to the level of the capacity which is contained in existing contracts on the date of VIP-establishment. After the end of a contract the capacity becomes available and is marketed at the VIP
The technical capacity of the VIP consists of the available capacities of the IPs constituting the respective VIP
Process for existing contracts
Nominations for existing contracts take place at the IP, Nominations for new contracts at the VIP
- Should existing contracts at the other side of the border be transferred to the VIP, the existing contracts are to be nominated at the IP on the German side and at the VIP on the other side. The German TSOs together with the partners on the other side of the border will ensure the execution of the transport.
Capacity surrendered from existing contracts is remarketed at the VIP
Long Term UIOLI: Identification of the congestion will consider all relevant points, identification of use and withdrawal per IP, marketing of withdrawn capacity at the VIP
Short Term UIOLI: Identification of the limits for application and renomination per IP, marketing of capacities made available at the VIP
Secondary marketing of existing contracts takes place at the IP
Nomination management / Matching
Contractual verification of nominations at each IP and at the VIP
- Afterwards aggregation of received nominations per border in order to ensure the transport execution also in cases where existing contracts are transferred to the VIP on the other side of the border
Aggregated nominations are transmitted to the adjacent TSOs for the matching
Balancing group managers can only over-nominate at the VIP
Over-nomination at the IP is excluded as all available capacity is marketed at the VIP
The complete booking of the VIP capacities is the condition for allowing over-nominations at the VIP
Bundled Nomination (Single-Sided-Nomination) will be offered from VIP to VIP
„Bundling Conversion“ (NC CAM)
Converting an unbundled existing contract on the German side of the IP is only possible by booking bundled capacity at the IP until the date of VIP establishment
Unbundled IP-capacities on the German side of the IP cannot be converted anymore after the date of VIP establishment
Should an unbundled existing contract on the other side of the border be transferred to the VIP, the conversion via booking of bundled capacity at the VIP should still be possible based on the requirements of the TSO on the other side of the border
„Upgrade Conversion“ (GasNZV)
Conversion of existing contracts for interruptible capacity or firm capacities with interruptible elements at the IP to firm capacities or firm capacity products with less interruptible elements are only possible by booking such capacities (according to TSO specific product ranking) at the IP until the date of VIP establishment
After the date of VIP establishment, an upgrade at the IP is not possible anymore
The TSOs responsible for each VIP will inform the market on a continuous basis on the implementation status at the respective VIP.
Status of the conversion at the relevant VIP
VIP NCG Oberkappel (Status: 21 February 2019)
|VIP NCG Oberkappel||NCG|
|VIP-TSO||Open Grid Europe|
|Concerned TSOs||GRTgaz Deutschland, Open Grid Europe|
Oberkappel (GRTgaz Deutschland), Oberkappel (Open Grid Europe)
As described in the market information of May 2018, establishing a VIP between NCG and the Market area East including the points Oberkappel and Überackern is not possible. Upon written request by the Federal Network Agency (Bundesnetzagentur), the TSOs GRTgaz Deutschland and Open Grid Europe have decided to establish a VIP only at Oberkappel in Germany.
The TSOs will thus establish the VIP NCG Oberkappel on the German side of said interconnection point on 1 March 2019. This implementation date has been communicated to Gas Connect Austria and the Bundesnetzagentur.
Further details regarding the implementation of these VIPs (e.g. the EIC-Codes) are available under the download section. The TSOs underline that the changes due to the VIP establishment concern only the German side of the interconnection point.
VIP France-NCG and VIP Czech Republic-NCG (Status: 21 February 2019)
|Concerned TSOs||GRTgaz||GRTgaz Deutschland, OGE|
|Relevant IPs||Obergailbach||Medelsheim GRTgaz
Deutschland, Medelsheim OGE
|Concerned TSOs||NET4GAS||GRTgaz Deutschland, OGE|
|Relevant IPs||Waidhaus||Waidhaus GRTgaz
Deutschland, Waidhaus OGE
Due to the uncertainties regarding the VIP-establishment as well as the risks involved, the TSOs were for a long time unable to initiate the adaptations to the core processes and IT-systems required for VIP-implementation. The implementation of VIPs has implications for the whole complex IT-landscape of the TSOs. In particular time-critical, highly-available systems and processes like nomination and grid steering systems are affected. Due to the criticality of these systems and processes a comprehensive quality assurance is imperative.
Therefore, the TSOs will establish the VIP France-NCG and the VIP Czech Republic-NCG by 1.3.2019. This implementation date has been coordinated with the adjacent TSOs and the Federal Network Agency (Bundesnetzagentur) has been informed.
Further details regarding the implementation of these VIPs (e.g. the EIC-Codes) are available under the download section.
VIP L GASPOOL-NCG
The VIP L GASPOOL-NCG will be established by 1. November 2018. Due to the fact that this VIP only involves Open Grid Europe on the NCG-side of the border the implementation of this VIP is relatively easy and the establishment can therefore be managed by 1.11.2018. Also on the Gaspool-side, due to the lower complexity (transfer of new “existing contracts” to the VIP by Nowega and GUD) the establishment of the VIP L GASPOOL-NCG by 1.11.2018 is realistic.
|VIP L GASPOOL-NCG||GASPOOL||NCG|
|Concerned TSOs||NOWEGA, GUD||OGE|
|Relevant IPs||Zone OGE L, Ahlten, Steinbrink||Zone GUD L, Ahlten, Steinbrink|
EIC-Code of „VIP L GASPOOL-NCG“: 37Z000000007353T
Marketing begin for VIP capacities: The marketing of capacities at the VIP will start with the Day-Ahead auction on 31.10.2018 for the gas day 1.11.2018.
VIP-tariffs: With regards to the VIP-tariffs, the TSOs refer to the price sheets of the VIP TSOs NOWEGA and OGE.
VIP NCG-Belgium and VIP NCG-Switzerland (Status: 4 February 2019)
|VIP-TSO||Fluxys Belgium||Open Grid Europe|
|Concerned TSOs||Fluxys Belgium||Fluxys TENP, OGE, TG|
|Relevant IPs||Eynatten 2||Eynatten-Raeren, Eynatten, Lichtenbusch|
|VIP-TSO||No application of NC CAM||Fluxys TENP|
|Concerned TSOs||FluxSwiss, SwissGas||Fluxys TENP, OGE|
|Relevant IPs||Wallbach||Wallbach Fluxys TENP, Wallbach OGE|
The abovementioned TSOs are currently working on the establishment of the VIPs NCG-Belgium and NCG-Switzerland. The implementation of VIPs has implications for the whole complex IT-landscape of the TSOs. In particular time-critical, highly-available systems and processes like nomination and grid steering systems are affected. Due to the criticality of these systems and processes as well as mutual dependencies between the TSO’s IT systems a comprehensive quality assurance is imperative. This requires more time than originally expected.
Therefore, the TSOs will establish the VIP NCG-Belgium and the VIP NCG-Switzerland on 1 July 2019 and will only market VIP capacities from that day on. In order to allow our customers to book VIP capacities early on, TSOs will market only VIP capacities already in the following auctions:
Quarterly auctions in May 2019 for the transport period 1.7.2019 – 1.10.2019
Monthly auctions in June 2019 for the transport period July 2019
Yearly auctions in July 2019 for the transport period gas year 2019/2020 and following
Day Ahead/Within Day-auctions starting on 30 June 2019 for the transport period starting on 1 July 2019
This approach is coordinated with the adjacent TSOs and the regulator is informed.
Further details regarding the implementation of these VIPs (e.g. the EIC-Codes) will be communicated with sufficient lead-time. The concerned TSOs would like to underline again that no major changes in operations are to be expected from the customer’s point of view. This is the case in particular for customers that are already active at the relevant IPs. As Open Grid Europe will be the “VIP-TSO” for the VIP NCG-Belgium and Fluxys TENP the “VIP-TSO” for the VIP NCG-Switzerland and today’s processes will remain largely unchanged, the requirements for the customer before grid use are mainly to register with the VIP-TSO via PRISMA if they are not already registered with that TSO and perform a communication test. Such a registration is already possible today. The VIP-TSO will provide sufficient time for registration and establishment of interfaces.
VIP NCG-Netherlands H-Gas and VIP NCG-Netherlands L-Gas
|Concerned TSOs||GTS||Fluxys TENP, OGE, TG|
|Relevant IPs||Bocholtz, Oude Statenzijl 1, Bocholtz-Vetschau||Bocholtz (Fluxys TENP), Bocholtz (OGE), Oude Statenzijl, Bocholtz-Vetschau|
|Concerned TSOs||GTS||OGE, TG|
|Relevant IPs||Winterswijk, Tegelen, Haanrade, Zevenaar||Elten, Vreden, Tegelen, Haanrade, Zevenaar|
On 28 June 2018 the adjacent TSO Gasunie Transport Services (GTS) has published its decision to implement VIPs in Q1 2020 under the condition that the NC TAR with a postage stamp tariff mechanism as RPM is implemented by then in the Netherlands.
The TSOs active at the border between NCG and the Netherlands are in contact with GTS and are going to restart the coordination meetings for VIP implementation soon. Based on current knowledge, the establishment of these VIPs in Q1 2020 also seems feasible for the TSOs in the NCG market area.